Surviving a Medicare Shoe Audit Presented by Josh White, DPM, CPed President/Founder SafeStep Codingline Expert Panelist Member APMA DME Subcommittee
Understanding Documentation Requirements: Goal: o Gain a better understanding of the documentation requirements for the Medicare Therapeutic Shoe Program. o Access a checklist and see the documents that are created by our WorryFree DME Program. www.aappm.org
Objectives Explain compliance documentation required by the Medicare Therapeutic Shoe Program Audits = Fear Present the WorryFree DME solution
DOCUMENTATION CHECKLIST FOR THERAPEUTIC SHOES Page 2
Simply Stated: 1. Prescription for Diabetic Shoes and Inserts 2. Documentation of Patient Evaluation Prior to Shoe Selection 3. Statement of Certifying Physician for Therapeutic Shoes sign on or after the date of the in-person visit and within 3 months prior to the delivery of the shoes / inserts 4. Information from Medical Records of In-Person Visit with DPM Documenting that Beneficiary has Qualifying Risk Factors for Therapeutic Shoes 5. Proof of Delivery...Delivery Documentation and Break in Instructions + Supplier Standards 6. Dispensing Chart Notes for Therapeutic Shoes
Let s break it down Medicare Compliance Documentation required of Shoe Supplier From DPM Pre-fitting exam (CDFE) RX Certificate of Receipt Dispensing SOAP Notes From MD/DO Certifying Statement Relevant Medical Records
1st of 6 required documents: Rx ~ Treating Physicians detailed written order Prescription- Shoes and Inserts
2nd of 6 required documents: Supplier in person evaluation, Exam perform prior to shoe selection (CDFE)
3rd of 6 required documents: Documents form Certifying Physician that meet LCD criteria: Relevant Medical Records and in-person visit- Signed by MD/DO Includes: Attestation that patient had been seen by MD for care of diabetes not more than 6 months prior and that they agree that patient needs shoes and inserts.
Continued Legible Signature
4th of 6 required documents: Statement of Certifying Physician for Therapeutic Shoes - Signed by MD/DO Expires in 90 days
4th of 6 required documents: Statement of Certifying Physician for Therapeutic Shoes - Signed by MD/DO A few things to note on the Statement of Certifying Physician Example SafeStep types the name of the Certifying Physician to comply with "legible signature"
5th of 6 required documents: Documents from Prescribing Physician, Dispensing SOAP Note DPM/Supplier signs and saves Dispensing SOAP Note Dr. Write Wells
6th of 6 required documents: Proof of Delivery Certificate of Receipt- Signed by Patient
So what is happening Why are there so many prepayment audits... Are there many failures... Why are there so many failures What did you do wrong...
Pre-payment audit letters are sent to less than 10% of all DPM's... Receiving a letter does not indicate that anything has been done wrong... It is an inquiry to be sure all documentation is clear and available. http://www.cgsmedicare.com/jc/pubs/news/2 011/0111/cope13769.html http://www.cgsmedicare.com/jc/pubs/news/2 011/0111/cope13769.html
This is an audit letter
let s understand what is needed
In order to meet criterion 2, the certifying physician must either: 1. Personally document one or more of criteria a f in the medical record of an in-person visit within 6 months prior to delivery of the shoes/inserts and prior to or on the same day as signing the certification statement; OR 2. Obtain, initial/sign, date (prior to or on the same day as signing the certification statement), and indicate agreement with information from the medical records of an in-person visit with a podiatrist, other M.D or D.O., physician assistant, nurse practitioner, or clinical nurse specialist that is within 6 months prior to delivery of the shoes/inserts, and that documents one of more of criteria a f.
SafeStep collects the results of the CDFE to create a report that is sent to the certifying physician, along with a cover letter and the "Statement of Therapeutic Necessity". To make things perfectly clear to the auditor, we call this report, "Information from Medical Records of In-Person Visit with DPM Documenting that Beneficiary has Qualifying Risk Factors for Therapeutic Shoes". It includes the following statements and then requests signature and date from the certifying physician: o "I am the MD supervising "PATIENT NAME'S" comprehensive plan of care for Diabetes Mellitus. I agree with the above findings and that he patient needs therapeutic shoes and inserts. As required by Medicare, this report is to be incorporated as pat of my medical records and if requested, a copy will be provided. " o "Date "PATIENT NAME" last seen by Dr. MD/ DO during which diabetes management was addressed: DATE.
"No documentation submitted of an in-person visit with the patient by the certifying physician during which diabetes management is addressed within 6 months prior to delivery of shoes/inserts." If get a denial of prepayment audit for not meeting criteria 3, obtain actual chart notes consistent with MD/DO attestation (medical records) and submit with re-determination.
How to contest an audit... If fail audit, does not mean that documentation was incorrect. Consider appealing! Sample Re-determination form Link to Re-determination guide on SafeStep website
Issues contributing to podiatrists not utilizing the Medicare shoe program: A host of issues have contributed to many podiatrists not utilizing the Medicare shoe program. Fear of Medicare audits based on lack of understanding of compliance requirements. Difficulty complying with revised Medicare documentation requirements. Lack of cooperation from certifying physicians who are required to sign and date compliance documentation. http://www.safestep.net/members/sectioncompliance.asp?orderforid=6567 http://www.cgsmedicare.com/jc/pubs/news/2011/0111/cope13769.html
References Local Coverage Determination and Policy Article titled Therapeutic Shoes for Persons with Diabetes o http://www.medicarenhic.com o http://www.cms.hhs.gov/mcd/search.asp Healthcare Fraud Charges o http://www.fbi.gov/milwaukee/pressreleases/2011/mw041111.htm o DMEPOSAccreditationStandards
Summary Medicare has initiated many audits and a lot of practices have failed A consequence is that the number of diabetic shoes dispensed have decreased significantly Medicare has clearly provided information about documentation requirements A solution exists such that physician suppliers can confidently participate in the Medicare Therapeutic Shoe program...it's called WorryFree DME
Don't be overwhelmed...there is a SOLUTION!
Step by Step How the process works: Every Patient with diabetes and Medicare should be scheduled for annual CDFE (pre fitting exam) Patients having qualifying risk factors are fit for shoes and shoe selection made
Pre-Fitting Exam Supplier in-person evaluation conducted prior to selection of items that documents an examination of the beneficiary's feet with a description of the abnormalities; specified Medicare requirements: Neurological exam Vascular exam Dermatological exam among other qualifying risks factors that establish the need for shoes/inserts/modification s
PQRS G8410, 2028F
Step by Step How the process works: WorryFree DME sends Certifying Statement and Relevant Medical Records from DPM CDFE findings to MD so that staff does not have to. 1. Certifying Statement 2. Relevant Medical Records (physician exam findings) Includes: Attestation that patient had been seen by MD for care of diabetes not more than 6 months prior and that they agree that patient needs shoes and inserts.
Step by Step How the process works: MD faxes to SafeStep signed, dated copies of 1. Certifying Statement (3rd form of 6) 2. Relevant Medical Records (physician exam findings) {4th form of 6} Documents are reviewed to ensure complete and compliant (reviewed to guarantee Medicare compliant) Also that patient seen by MD within 6 months Archived online
Step by Step How the process works: The Shipping Process Documentation, shoes and inserts shipped by SafeStep to DPM
Step by Step How the process works: DPM fits shoes and inserts. Indicates on website and prints out: o Dispensing SOAP Note (5th form of 6) SafeStep WorryFree DME creates dispensing SOAP note (no need for dictation) after shoes indicated as dispensed.
Step by Step How the process works: When shoes received by DPM, staff indicates on website and prints out: Patient Certificate of Receipt (6th form of 6) SafeStep WorryFree DME creates certificate of receipt and supplier standards when shoes come in. Cert. of Receipt includes patient address and mention of warranty as required by Medicare
Streamlining utilization: SafeStep WorryFree DME: Identify every patient in practice with Medicare and DM. Perform CDFE on every one; if qualify, use display stand to fit for shoes. Enter orders using WFDME, let SafeStep take it from there.
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